ML20207D280
| ML20207D280 | |
| Person / Time | |
|---|---|
| Issue date: | 08/26/1983 |
| From: | Whitney L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20151H089 | List:
|
| References | |
| FOIA-88-92 NUDOCS 8808150311 | |
| Download: ML20207D280 (4) | |
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A.UG 2 61983 2 Y'E " - [Ol' b -
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~ ,- MEMORANDUM FOR: James M. Taylor, Director ,...,.y '. Division of Quality Assurance, Safeguardsi ' - i and Inspection Programs !
Office of Inspection and Enforcement THRU: Phillip F. McKee, Chief Section 1, Operating Reactor Programs Branch Division of Quality Assurance, Safeguards, and Inspection Programs Office of Inspection and Enforcement FROM: Leon E. Whitney
- Lead Staff Contact for Fire Protection Section 1, Operating Reactor Programs Branch Division of Quality Assurance, Safeguards, and Inspectinn Programs Office of Inspection and Enforcement
SUBJECT:
IE/ REGIONAL SAFE SHUTDOWfl INSPECTION PROGRAM FY 1983 REVIEW /FY 1984 PLANNING MEETING l Date and Tire: September 13 and 14,1983 Starting 9:0D a.m. L , cation: East / West Towers, South Building Bethesda, Maryland Fourth Floor Conference Room, Room 465
Purpose:
Review safe shutdown inspections to date; plan FY 1984 safe shutdown inspection effort; discuss various safe shutdown inspection and general fire prc:ection issues. Particicants: See enclosed agenda. . l Leon E. Whitney . Lead Staff Contact for Fire Protection l Section 1, Operating Reactor Programs Branch ' Division of Quality Assurance, Safeguards, an'd Inspection Programs Office of Inspection and Enforcement
Enclosure:
Acenda 1
.ribution:
'IE Files / lE Reading / ORPB .teading / DQASIP Reading / L. E. Whitney /
P. F. Meree / J. G. Partlow / C. Anderson, RI / S. Ric 4 D11 / T. Conlon, RII / W. Miller, RII / C. Williams, RIII / . Maura, RI]Il / M. Murphy, RIV / R. Mulliken, RIV / G. Zwetzig, RV / . 5ccwn, RV / 0. Parr / J. Werniel / V. Benaroya / R. Ferguson / F. Nolan / T. Wambach / D. Brinkman / E. L. Jordan / A. Muir / W. Luckas, BNL / J. Taylor, SNL / E. B. Ele \ woo,d, EDO 8809150311 080705 r PDR FOIA 3FFICIAL RECORD COPY JONES 88-92 PDR OFFICT: ORPB:D :IE ORPB:DQASIP:IE DD:00ASIP:!E NAME: g. T. QA ~ . P. F. McKee J. G. Partlow DATE: 8/ h/33 8/ /83 8/ /83 gg
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SAFE SHUTDOWN INSPECTION PROGRAM MEETING AGENDA. TUESDAY, SEPTEMBER 13, 19.3 9:00 a.m. Session I - Inspe' ction Program Administration Attendees: C. Anderson, Region I S. Richards, Region I T. Conlon, Regicn II ' W. Miller, Region 11 C. Williams, Region III _ F. Maura, Region III M. Murphy, Region IV ! R. Mulliken, Region IV l K. Scown, Region V j 12:30 p.m. Session II - Safe Shutdown Inspection Procram Review and Planning )
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Attendees: All above i' CMEB, NRR ASB, NRR l BNL I 1 i Tooics: Discussion Leader Inspection and Enforcement Actions L. E. Whitney to date Recent NRR Staff Positions CMEB/ASE 50.48(b) SER Open Item Determination T. Conlon Planned Actions for Fiscal Year 1984/ Conmission Paper Draf t Review Information L. E. Whitney e w e eT*y w e -ir 4yy >p .' w.-,
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_- . ,~- -_- 4 e f* FIRE PROTECTION ISSUES MEETING AGENDA WEDNESDAY, SEPTEMBER 14, 1983 9:00 a.m. Session l'II - Fire Protection . Attendees: See Session II attendee listing
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Topics: Discussion Leader
- 1. Fire Pump Tests - Acceptable Performance K. Scown, Region V Tests
- 2. Fire Detection - Codes, Technical Specifications, Basis
- 3. Technical Specifications for Fire otection
- 4. Licensee Commitments - Letters, FHA, FSAR, fJPA Codes - Enforcement and Inspectability S. Interface of Requirements - Appendix R to BTP 9.5-1,to NUREG-0800
- 6. Inspection Modules - Possible Revision -
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- 7. CA Requirements for Fire Protection i IEB S3-41, June 19, 1983 j
- 8. Emergency Lighting Requirements
- 9. Oil Collection System (RCP) 1
- 10. Fire Doors and Dampers I 1
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a r- > , Topics: , Discursion Leader
- 11. Penetration Barriers and Seals: ;
- Acceptable P,aterial for Test Results l l
Acceptable Test Documentation ;
- What is an Acceptable Testing Laboratory? l l
- 12. CRGR:
- Review of Fire Protection Requirements l
- 13. Ventilation Systems l
- 14. Other Topics as Identified
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n le g TO ALL LICENSEES AND APPLICANTS OF NUCLEAR POWER REACTORS
-- l Gentlemen:
SUBJECT:
NRC POSITIONS ON CERTAIN REQUIREMENTS OF APPENDIX R TO 10 CFR 50 (GENERIC LETTER 83-33) l, During our evaluations of exenption requests, we determined that some ; licensees were interpreting certain requirements of Appendix R in a manner ! that was not consistent with the position that the staff was using. Where ' any such differences were discovered, we infomed these licensees in the NRC Safety Evaluation Report supporting tne granting or denial of.an exemption. More recently, we have completed inspections for confomance to Appendix R at four plants, the licensees for which had indicated that
- e. all modifications for confomance had been completed or other modifications l approved by exemptions had been completed. In these inspections, the NRC i (m inspection team also identified what the staff considers to be non- l l conformancewithrequirementsofAppendixR,forwhichexemptionshadnot'l been requested or justified.
Therefore, we are transmitting the enclosure to all licensees and applicants for infomation and use as appropriate. The NRC inspection teams that will be conducting the inspections for confomance to Appendix R at each plant will be using these positions as their criteria for confomance for these particular issues. No written response to this letter is required. Sincerely,
.r.. qi-Darrell G. Eisennut, Director Division of Licensing Office of Nuclear Reactor Regulation
Enclosure:
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. . . NRC Staff Positions on Certain
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Requirements of Appendix R to 10 CFR 50
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Introduction During our reviews of Appendix R exemption requests and cur review of appli-cations for operating licenses, it has become apparent that certain require-ments of Appendix R to 10 CFR 50 and the corresponding guidelines in
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SRP 9.5-l were not being interpreted correctly by some licensees. On several occasions members of the staff met with representatives of the Nuclear Utility Fire Protection Group (NUFPG), other industry representa-tives, and individual licensees to di$ss clarification of certain requirements. The staff agreed to send the staff positions on these issues to all licensees.
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- 1. Detection And Automatic Suppression
-( Staff Position: Subsections III.G.2.b, III.G.2.c, and III.G.2.e require that fire de(ectors and an automatic fire suppression system be installed "in" eny
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fire area. To satisfy this requirement, the fire detectors and automatic l suppression system need to be installed "throughout" the fire area. Some licensees have not interpreted "in" the fire area to require full detection and suppression "throughout" the fire area. This interpre-tation makes the requirement ambiguous, In some fire areas, however, the installation of a fire detection and a fire suppression systen throughout the fire area may not significantly increase the level of fire safety afforded by only partial coverage; or the installa-( tion of a firc suppression system throughout the area may be detrimental to 3. . , overall plant safety. Such areas must be evaluated under the exemption ", process, al,ong.,yith o i a fire hazards analysis that shows the installation of { ( fire detection and/or suppression systems in only select locations within , [ '4 , . . I the fire area will provide an equivalent level of protection, f.. .,,; , , feAsuE - , ,- Ib b HG*~.,R N A 6 M W lo Q hA c@,3 $ 3 I '
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- 2. Fire Areas 1*$-33 ,
A ( ' T. [at Staff Position: Section III.G of Appen' dix R sets forth the requirement ~ ' ' ~ ' ' for fire protection for safe shutdowr, capability on the basis of fire are'as. ~
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A fire area is defined as t(at portion of a building _ or plant _that-14 i 1 separated from other areas by boundary fire barrier 1.(walls, floors and
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ceilings w ith any openings or penetrations protected with seals or closures i having a fire resistance rating equal to that required of the barrier). Open stairwells and hatchways in ceilings and floors are not fire area boundaries. For boundary fire barriers, using walls, floors, ceilings, dampers, doors, etc. existing prior to Appendix R, the rating required of a boundary I fire barrier is based on the guidance in Appendix A to BTP ASB 9.5-1, i.e. , (
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the rating of the barrier or boundary must exceed with margin the fire loading I ['" in the area and need not necessarily be a 3-hour rated boundary unless the k - fire loading warrants such a boundary. For modifications which involve the installation of new boundary fire barriers pursuant to Section III.G.2.a. the fire rating of such boundaries must be three hours, or an exemption must be justified and requested. The evaluations by some licensees made prior to Appendix R v are based on fire zones which do not meet the strict definition of fire areas clarified above. In some cases, the separation of redundant trains under consideration { I within the "fire zone boundaries" and the separation between fire zones does not comply with the separation, f.e., barrier or distance, requirements of Appendix R. Such configur4ations need to be evaluated under the exemption process. N The fire protection requirements are i5 ended to provide reasonable assurance that at least one safe shutdown division is free of fire damage
} after a postulated fire in any fire area. The definition of "fire areas,"
5 noted above, is predicated on sound fire protection engineering principlas
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as they apply to.. limiting the fire and fire suppressant damage to redundant j shutdown equipment and cables. Fire. areas defined by non-physical bounda-l ries, such as "logical divisions" or "equipment groupings", may not necessari-ly- , -- - restrict fire and smoke spread, and do not necessarily provide-reasonable assurance that the limits of fire or fire suppressant damaae to shutdown systems have been defined.
-In many pl6nt areas, however, the erection of physical barriers between 1
redundant shutdown systems is precluded by the location of cable trays, l HVAC ducts and other plant features. In such situations, the staff has accepted, in concept, the use of an automatic fire suppression system which discharges a "water curtain" across the boundary areas separating the redundant systeras. The design of such "water curtains" has not been codified, f.e., the National Fire Protection Association Standards do not address the use of fire suppression systems for such applications. How-m,. ever, the staff is currently working with several applicants and licensees to define design requirements which will satisfy mutual concerns. The staf f's (resent position is that such systems should feature close-spaced, open-head sprinklers with water discharge initiated by tripping a deluge valve activated by cross-zoned smoke detectors. Where smoke propagation does not represent a hazard to redundant shutdown systems, a close-space, close-head sprinkler system may be deemed acceptable. Where such "water curtains" are used, the operation of such systems should not endanger safety systems on either side of the "water curtains."
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- 3. Structural Steel Related To Fire Barriers Staff Position: Appendix R requires that structural steel forming a part i of, or supporting a fire barrier separating redundant trains shall be pro-tected so M to have a fire rating equivalent to the fire resistance I required of the barrier.
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The protection of structural steel is required because steel loses 7 strength when subjected to temperatures that may be attained in a fire. ( ._ 1100 degrees Fahrenneit is nomally considered to be the critical tempera- ' ture. At this temperature the yield stress in steel has decreased to ab6ut ~ ~ "' 60 percent of the value at room temperature. This is approximately the , level nomally used as the design working stress. Because steel has a high thermal conductivity 2 and heat is transferred away from a localized , heat source, rather quickly, a relatively long period of time is required to reach the critical temperature. However, an exposure fire that dis-tributes heat over a greater area may reduce this time considerably. Structural steel need only be rated to the level of the barrier of which it is a part, based on the combustible loading in the area. 'If protection is required to achieve such a rating, then the steel would have to be protected. In cases where the structural steel is not protected and has a lower fire rating than the required rating of the fire barrier, an exemption must be requested and justified by a fire hazards analysis which shows the [ N temperature the steel will reach during fire, and the ability of the steel to carry the required loads at that temperature.
- 4. Fixed Suppression System Staff Position: A fixed fire suppression system shall have discharge heads and the distribution piping for such heads installed. Hose stations do not satisfy this requirements, f The majority of areas for which a fixed fire suppression system is _
required contain large concentrations of cables and, therefore, have high fire loadings. In addition, access for fire fighting may be hampered by congestion and smoke. A fir ' e suppression system should be capable of controlling a fire in such areas even under limited access conditions.
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- 5. Intervening combustibles 1 Staff Position: Section III.G.2.b require's the "separation . . . with no )
intervening combustibles . . ." To meet this requirement, plastic jackets-- - --- and insulation of grouped electrical cables, including those which are coated, should be considered as intervening combustibles. I Numerou; comprehensive flaminability tests conducted by the Electric
. Power Research Institute (EPRI NP-1200, EPRI EL-1263), Factory Mutual (Cdntract RP-il65-1), and Sandia National Laboratories (NUREG/CR-2431, among others) have shown that burning plastic cable insulation represents l a significant fire hazard. These tests were conducted on both IEEE-383 qualified and unqualified cable. While the qualified cable exhibited a tendency to ignite and propagate flame less rapidly, combustion of grouped l cables continued at significant levels. In particular, grouped vertical cables which are not protected by a fire propagation retardant, such as /~ ' metal tray covers or fire retardant coatings, can result in rapidly l \ developing fires with high heat release rates. i t l
- 6. Transient Fire Hazards Staff Position: When addressing transient combustibles in exemption requests, the fire hazards analysis should consider the conservative bounding value for a transient fire hazard that could reasonably be expected over the life of the plant.
Over the past few several yt.srs, several attempts have been made by the NRC and industry to develop criteria for establishing "design basis transient combustibles." These have been suggested:
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The maximum amounts permitted by the_ plant's administrative 1. controls or some multiple of that emount. ( '
- 2. Selected amounts (e.g.,1 pint,1 quart, or 1-20 gallons) of a combustible liquid (e.g., acetone, heptane, lube oil, or solvents). -
I However, none of these ctiteria have stood up to critical evaluation as to '
..why they are bounding conditions in all possible circumstances. During the life of the plant, transient combustible materials may be located in, or J pass through safety related areas. These hazards arise from activities associated with operation, maintenance, repairs or modifications. They l may arrive deliberately under approved work permits or inadvertently as a temporary expedient. Usually, a fire involving such materials would ;
not overpower the fire protection features provided in accordance with Section III.G and, therefore, are only of concern when exemptions or deviations are equested. ( $ In reviewing "transient combustibles" when evaluating exemption requests, l the staff considers, among other things: (1) the physical attributes of the area that will tend to limit the amounts of transient combustibles, e.'g., restricted access due to the environment within the area and loca-tion of the area or physical acces3 limitations; (2) whether the fire area is required by the plant Technical Specifications to be manned continuously; (3) the physical attributes of the fire area and configuration of the systems of concern which apply to their capability to limit fire and fire suppressant danage; and (4) the safety significance of the systems of .. concern.
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'k DISTRlbuTION LIST FOR FIRE PROTECTION MEMO TO DIRCKS DTD 10/26/84 H. Denton, NRR
- R. Minogue, RES R. DeYoung, IE T. Speis, DST D. Eisenhut, DL H. Thompson, HFS R. Bernero, DSI E. Case, NRR G. Arlotto, RES T. Murley, R-1 J. O'Reilly, R-II J. Keppler, R-Ill m R. Martin, R-IV J. Martin, R-V R. Fraley, ACRS R. Vollmer, DE ,
N. Grace, IE J. Olshinski, R-II
-.., L. Spessard, R-Ill W. Olmstead, ELD C_ W. Shields, ELD J. Axelrad, ELD T. Wambach, DL J. Taylor, IE V. Benaroya, NRR W. Little, R-III -
F. Rosa, NRR ] S. Richardson, IE S. PUllani, R-1 W. Miller, R-Il P. Madden, R-l'. Rfil 1 J. Ulie, R-III - M. Murphy, R-IV R. Cooper, II, IE L. Whitney, IE R. Eberly, NRR J. Stang, NRR R. Ferguson, NRR W. Johnston, NRR C. Grimes, DL V. Moore, HFS C. Ar.derson, R-I T. Conlon, R-II
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d!!F y;gg TO ALL LICENSEES AND APPLICANTS OF NUCLEAR ! POWER REACTORS Gentlemen:
SUBJECT:
NRC POSITIONS ON CERTAIN REQUIREMENTS OF APPENDIX R l TO 10 CFR 50 (GENERIC LETTER 83-33) During our evaluations of exenption requests, we detemined that some licensees were interpreting certain requirements of Appendix R in a manner that was not consistent with the position that the staff was using. Where any such differences were discovered, we infomed these licensees in the NRC Safety Evaluation Report supporting the granting or denial o'f an exemption. More recently, we have completed inspections for conformance to Appendix R at four plants, the licensees for which had indicated that all modifications for conferrnance had been completed or other madifications I approved by exemptions had been completed. In these inspections, the NRC ! ( inspection team also identified what the staff considers to be non-conformance with requirements of Appendix R, for which exemptions had nnt been requested or justified. Therefore, we are transmitting the enclosure to all licensees and applicants for information and use as appropriate. The NRC inspection teams that will be conducting the inspections for conformance to Appendix R at each plant will be using these positions as their criteria for conformance for these particular issues. No written response to this letter is required. Sincerely, r Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulaticn
Enclosure:
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- 2. Fire Areas g.
N. A Staff Position: Section III.G of Appendix R sets forth the requirecient for fire protection for safe shutdown capability on the basis of fire areas. NE
-.h A fire area is defined aLth.a.t_ gor _ tion of a buildigor p,lant that.is
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- . . . . areas by boun_dary, fire barr.LerL(walls, floors and c
,, eilings wi,th any openings or penetrations protected with seals or closures \
having a fire resistance rating equal to that required of the barrier). Open stairwells and hatchways in ceilings and floors are not fire area boundaries. ! For boundary fire barriers, using wal*.s, floors, ceilings, dampers, ' doors, etc. existing prior to Appendix R, the rating required of a boundary fire barrier is based on the guidance in Appendix A to BTP ASB 9.5-1, i.e., the rating of the barrier or boundary must exceed with margin the fire loading in the area and need not necessarily be a 3-hour rated boundary unless the fire loading warrants such a coundary. For modifications which involve the installation of new boundary fire barriers pursuant to Section III.G.2.a , the fire rating of such boundaries must be three hours, or an exemption must be justified and requested. The evaluations by some licensees made prior,to Appendix R were based on ! fire zones above. which do not meet the strict definition of fire areas clarified . In some cases, the separation of redundant trains under consideration within the "fire zone boundaries" and the separation between fire zones does not comply with the separation, i.e., barrier or distance, requirements of Appendix R. l process. Such configurAations need to be evaluated under tne exemption The fire protection requirements are intended to provide reasonable N assurance that at least one safe shutdown division is free of fire damage af ter a postulated fire in any fire area. The definition of fire areas," ' noted above, is predicated on sound fire protection engineering principles
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l I g as they apply to limiting the fire and fire suppressant damage to redundant shutdown equipment and cables. Fire areas defined by non-physical bounda-
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ries, such as "logical divisions" or "equipment groupings", may not necessarily I restrict fire and smoke spread, and do not aecessarily provide reasonable assurance that the limits of fire or fire suppressant damaoe to shutdown systems have been defined.
-In many plant areas, however, the erection of physical barriers between l
redundant shutdown systems is precluded by the location of cable trays, HVAC ducts and other plant features. In such situations, the staff has accepted, in concept, the use of an automatic fire suppression system which discharges a "water curtain" across the boundary areas separating the redundant systems. The design of such "water curtains" has not been codified, i.e., the National Fire protection Association Standards do not address the use of fire suppression systems for such applications. ' How-ever, the staff is currently working with several applicants and licensees to define design requirements which will satisfy mutual concerns. The staff's present position is that such systems should feature close-spaced, open-head sprinklers with water discharge initiated by tripping a deluge valve activated by cross-zoned smoke detectors. Where smoke propagation does not represent a hazard to redundant shutdown systems, a close-space, close-head sprinkler system may be deemed acceptable. Where such "water curtains" are used, the operation of such systems should not endanger safety systems on either side of the "water curtains."
- 3. Structural Steel Related To Fire Barriers Staff position:
Appendix R requires that structural steel forming a part l of, or supporting a fire barrier separating redundant trains shall be pro-tected so as to have a fire rating equivalent to the fire resistance required of the barrier. l l
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.c 72ew' 14 arch 23, 1984
-ie> TO ALL LICENSEES SUBJECT TO APPEf4 DIX R TO 10 CFR PART 50:
Enclosed are four documents on the subject of the fire protection program at your facility mandated by 10 CFR 50.48 and Appendix R to 10 CFR Part 50. En-closure 1 contains NRC staff interpretations of certain Appendix R provisions. In some cases the interpretations differ from those contained in previous staff guidance. Enclosure 2 contains questions developed as a result of the industry-sponsored Fire Protection Seminar held recently in Washington, DC. and NRC ks staff responses to those questions. Enclosure 3 contains additional questions and answers which came to the staff's attention subsequent to the seminar. En-closure 4 is a complete list of previous staff guidance on the fire protection program. Uhere guidance has been modified by the interpretations in Enclosure 1, it is so noted. These documents are being provided informally at this time, and may be added to or otherwise modified during the remainder of the NRC Regional Workshops on fire protection. At the conclusion of the workshops, the revised guidance will be transmitted formally to all affected licen.er n. When this process is ccm-plete, the fiRC will no longer accept arguments that either the Conrission's rules or staff guidance on those rules has not been correctly understood.
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- g X. Fire Area. Boundaries l
QUESTION A. If a fire area boundary was described as a rated barri.er in the 1977. 5 fire hazards analysis, no open items existed in this area in the Appendix A SER, and the barriers have not been altered, then need those barriers be reviewed by licensees or the Staff under Appendix R?
RESPONSE
In BTP CMEB 9.5-1, Fire Barrier is defined as: ( "Fire Barrier - those components of construction (walls, floors, ad the supports), including beams, joists, columns, penetration seals or closures, fire doors, and fire dampers that are rated by approving laboratories in hours of resistance to fire and are used to prevent the spread of fire." If a fire boundary was described as a rated barrier in the 1977 fire hazards analysis, was evaluated and documented in a published SER, then those fire area boundaries need not be reviewed as part of the re-analysis for compliance with Section III.G of Appendix R. p v The term "fire area" as used in Appendix R means an area sufficiently bounded - a to withstand the hazards associat.d e wi.th the fire area a,nd g s y cessary, to protect important equipment within the fire area from a_ fire outside the
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Q 5 are. In order to ' meet the regulation, fire area boundaries need not be completely sealed floor-to-ceiling, wall-to-wall---.- boundaries. Where fire area boundaries were not approved under the Appendix A process, or where such boundaries are not wall-to-well, floor-to-ceiling boundaries with all penetrations shaled to the fire rating required of the boundry, licensees must perform an evaluation to assess the adequacy of fire area boundaries in their plants to determine if the boundaries are s.ufficient. This analysis must be performed by at least a fire protection engineer and, ! if required, a systems engineer. Although not re_ quired, licensees may submit their evaluations for Staff review and concurrence _. In any event, these analyses must be retained by the licensees for subsequent NRC ; audi,ts,. k , WW
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